how do I determine the data if my aluminium comes from mixed scrap

Mixed scrap requires a calculated composition, not separate traceability per batch

When aluminium has been melted from mixed scrap, the origin of each individual particle can no longer be traced — and it need not be. The ESPR requires reliable data on the product as it leaves the smelter or foundry, determined using the testing, measurement and calculation methods that apply to the product group (Article 39 of the ESPR, Regulation (EU) 2024/1781). For mixed scrap, this means in practice: the alloy composition, recycling content and origin of the raw material stream are determined at the level of the melt batch or production batch, not at the level of the individual scrap piece. What goes into the passport is therefore a calculated or measured average for that batch, not a sum of traceability declarations per piece of scrap.

For alloys from mixed streams, not for traceable batches

This approach applies to aluminium where the raw material — the scrap — comes from multiple, indistinguishable sources: for example post-consumer scrap from different collection streams, or a mix of own production waste and externally purchased scrap. As soon as scrap is delivered separately and traceably, for example a batch that can be demonstrated to come from one producer and one alloy type, there is no reason to treat it as "mixed": then the normal rules for recording origin and composition apply, just as they do for primary aluminium. The mixed-batch approach also does not apply to the legal question of who is responsible for providing the data — that remains the manufacturer or importer placing the aluminium on the market, regardless of whether the raw material was mixed. And it does not apply to imports from outside the EU with mixed origin; what the product passport means when importing from outside the European Union is a separate question with its own answer.

No fixed date yet, but a fixed methodology requirement

There is not yet a fixed date on which this obligation for aluminium enters into force; according to the ESPR work plan 2025-2030, the delegated act that works this out per product group is expected in 2027. Until that act is in place, it is already established that calculation methods for recycling content and composition are to be determined via such a delegated act (Article 39 of the ESPR), and that the regulation itself already indicates that circumvention of these rules and artificial deterioration of measured performance are not the intention (Article 40 of the ESPR). As soon as the delegated act for aluminium is published, including the calculation method for mixed scrap, that date will appear here.

How to handle mixed batches once the passport becomes mandatory

Start by recording at what level the mixed stream is created: does mixing occur before melting (different scrap batches together in the furnace) or after (different melt batches combined into one casting batch)? This determines at what point the composition must be measured or calculated. Next, ask your own scrap supplier what data on origin and composition are already known per delivery note, even if that data itself is already an average of a mixed stream — which data you request from your aluminium supplier is the starting point, and this applies to scrap suppliers just as much as to suppliers of primary aluminium. Record which calculation method was used to arrive at one composition for the batch from multiple input streams, and retain that underlying data even if not all of it goes into the passport itself — when checked, the ability to reconstruct the calculation counts. If the smelter works with scrap from multiple external suppliers for what ultimately becomes one alloy in the passport, the question is how data from multiple suppliers for the same alloy is combined in one passport directly applicable and worth reviewing. If part of the scrap cannot be traced back to a known source — for example, when purchasing via an intermediary without complete documentation — that is a separate issue with its own approach; see what to do when the origin of aluminium cannot be established. Also include the method of calculation in the agreements with scrap suppliers, in the same way as how the delivery of passport data is laid down in a purchasing contract describes that for other aluminium streams, so that a supplier does not switch to a different calculation method halfway through a contract period without notifying you.

The basis: Article 39 for the method, Article 40 against manipulation

That data on composition and recycling content are determined via an established method — and not freely, different per manufacturer — follows from Article 39 of the ESPR, which gives the Commission the authority to establish test, measurement and calculation methods per product group. For mixed scrap, that is the determining source: the method for aluminium, including how mixed streams are handled, comes from that delegated act, not from a manufacturer's own interpretation. Article 40 of the ESPR is relevant because it explicitly addresses the prevention of circumvention and artificial deterioration of performance in testing or calculation — a safeguard that carries particular weight with mixed and therefore more difficult to verify streams. And Article 10 of the ESPR describes in general terms what kind of data a digital product passport must contain, which is the framework within which the specific aluminium rules will find their place once they are established.

Companies already working with mixed scrap can derive the most benefit by now documenting at what level mixing takes place and what data come in per delivery note — that administration is usable once the calculation method for aluminium is established, and will then save reconstruction work afterwards.

What this is based on

The regulation itself is on EUR-Lex. We refer per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

Mixed scrap is the most normal thing in the world in the aluminium industry, and at the same time the place where a product passport will be most difficult to manage. With mixed scrap, the origin of the alloy cannot be traced back in a single line to a single supplier or a single production process, but is a mixture of batches, each with their own composition and history. The passport still has to say something meaningful about it.

Provide correct and substantiated data

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the content of the digital product passport: the data in it must correspond to the product to which the passport belongs. For a semi-finished product from mixed scrap, this means in practice: the composition stated in the passport is the composition of the actual melt or casting batch, not an estimate based on "usually this is our mix". For a company with 10 to 100 employees, this amounts to a step that is often not yet in place: linking the laboratory analysis of each melt (or batch) to the passports of the products made from it. Anyone already registering this per charge for their own quality assurance has already done most of the work.

Measure and calculate according to an accepted method

Article 39 of the ESPR concerns the test, measurement and calculation methods used to comply with product requirements. For mixed scrap, this article is relevant to the question of how you arrive at a percentage of recycled material or a composition: by measuring (spectrometry on the melt) or by calculating (mass balance based on input). For a foundry or profile maker, this means that the chosen method cannot be ad hoc — it must be applied consistently and, once the delegated acts for aluminium are in place, must align with what is prescribed as the method in those acts. Until then, it is sensible to already work with a method that aligns with what is considered standard practice in the sector, and to document that choice.

No circumvention and no deterioration of performance

Article 40 of the ESPR prohibits practices that circumvent the objectives of the regulation or that improperly affect the performance of a product. For mixed scrap, this is the article that calls for extra vigilance when "diluting" a problem: mixing a batch with an unfavourable or unknown composition with clean, well-documented batches so that the average falls within the standard is precisely the type of practice this article is aimed at. For a company with 10 to 100 employees, the practical side of this is that blending decisions — which batches make up the melt — are no longer purely technical or financial decisions, but also decisions that affect the passport.

Where things go wrong in practice

A few situations come up repeatedly with companies working with mixed scrap.

The composition is estimated, not measured. A charge is composed of different scrap streams, and the final alloy composition is derived from purchasing recipes rather than from an analysis of the melted batch. As long as that is good enough for your own standard, it does not immediately stand out — but the passport asks for the actual composition, not the theoretical one.

Scrap of unknown origin goes straight into the melting furnace. A batch arrives without clear documentation — sometimes via an intermediary, sometimes as a byproduct of a third party — and is melted in without anyone having recorded where it came from. What then goes into the passport is effectively a guess. See also what to do if the origin of the aluminium cannot be traced.

Multiple suppliers, one melt, one passport. When combining scrap from different suppliers for the same alloy, the question arises of which data from whom exactly ends up in the passport, and how you substantiate that if the suppliers themselves provide conflicting information. This does not only apply to scrap but to any purchase with multiple sources; see how you process data from multiple suppliers for the same alloy in one passport.

Deliberate blending to stay within the standard. A batch with a deviating composition — too much iron, a trace of an unwanted element — is deliberately mixed in small quantities with clean batches, so that the end result is on paper within the bandwidth. This is precisely the practice that article 40 of the ESPR targets, and it is a deliberate choice that is not simply explained if someone asks about it.

Subcontractors melt or process without their data being recorded. When the melting or preprocessing of scrap is outsourced, the source data often lies with that third party, and not with the company that ultimately draws up the passport. See or a subcontractor that processes the aluminium also has to provide data.

What you can document now

A record per melt or casting batch: which scrap streams went into it, in what proportion, and with which source documentation (weighing slip, certificate of origin, analysis certificate).
The laboratory analysis of each melt, linked to the charge or batch number that also appears in the passport.
The chosen measurement or calculation method for composition and recycling percentage, with a brief explanation of why that method was chosen — relevant under article 39 of the ESPR.
An internal blending policy: under which conditions batches from different origins or qualities may be melted together, and who grants permission for this.
Agreements with scrap suppliers on the minimum documentation that must accompany a batch — see also what data you can request from your aluminium supplier and how you record this in the purchase contract.
A fixed procedure for checking incoming data for plausibility, so that discrepancies between supplier information and your own analysis are identified — see how you verify your supplier's data for accuracy.
An overview of which subcontractors are involved in the melting or processing process, and what data from them are expected before a batch is considered "passport-ready".

This is not legal advice. This page provides general information on the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections are prioritised.